Mineral Resources International v. United States Department of Health & Human Services

53 F.3d 305
CourtCourt of Appeals for the Tenth Circuit
DecidedApril 19, 1995
DocketNos. 94-9523, 94-9524 and 94-9525
StatusPublished
Cited by1 cases

This text of 53 F.3d 305 (Mineral Resources International v. United States Department of Health & Human Services) is published on Counsel Stack Legal Research, covering Court of Appeals for the Tenth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Mineral Resources International v. United States Department of Health & Human Services, 53 F.3d 305 (10th Cir. 1995).

Opinion

ABARCÓN, Circuit Judge.

Mineral Resources International and Trace Mineral Research (hereinafter “Minerals”) seek review of regulations promulgated by the Federal Drug Administration (“FDA”) under sections 343(q) and 343(r) of the Federal Food, Drug, and Cosmetic Act, 21 U.S.C. § 301 (Supp. Y1993). Minerals maintain that we have jurisdiction pursuant to 21 U.S.C. § 371(f) (1988 & Supp. V 1993). Minerals contend that the regulations violate their First and Fifth Amendment rights and the Administrative Procedures Act (“APA”), 5 U.S.C. § 706 (1988). We do not reach the merits of Minerals’ assertions because we lack original jurisdiction to review the validity of regulations promulgated pursuant to sections 343(q) and 343(r).

I.BACKGROUND

In petition numbers 94-9523, 94-9524, and 94-9525, Minerals challenge the validity of the health claim regulation, the nutrient content regulation, and the nutrition labeling regulation, respectively. 59 Fed.Reg. 395 (1994) (codified at 21 C.F.R. § 20, 101); 59 Fed.Reg. 378 (1994) (to be codified at 21 C.F.R. § 101.54-101.69); 59 Fed.Reg. 363 (1994) (to be codified at 21 C.F.R. § 101.36). These regulations were promulgated by the FDA pursuant to the Nutrition Labeling and Education Act of 1990 (“NLEA”), Pub.L. No. 101-535,104 Stat. 2353 (codified at 21 U.S.C. § 343(q), (r) (Supp. V 1993)) which amended the Federal Food, Drug, and Cosmetic Act. The NLEA added sections 343(q) and 343(r) to that Act.

II.JURISDICTIONAL CHALLENGE

On April 29, 1994, the FDA filed a motion to dismiss the petitions for lack of subject matter jurisdiction. The FDA asserts that the regulations Minerals challenge were promulgated under sections 343(q) and 343(r). The FDA argues that this court lacks jurisdiction' to review' a regulation promulgated pursuant to section 343(q) or 343(r), because these sections are not specifically set forth in 21 U.S.C. § 371(e) (1988 & Supp V. 1993),

In their opposition to the FDA’s motion to dismiss, Minerals do not dispute the FDA’s position that the regulations were promulgated under sections 343(q) and 343(r). Instead, Minerals advance discrete theories to support their contention that this court has original subject matter jurisdiction over their petitions. Minerals assert that section 371(f) expressly authorizes review of their petitions by this court. Further, Minerals contend that this court has original jurisdiction as a result of the 1990 amendment to 21 U.S.C. § 371(a) (1988). Additionally, Minerals insist that their petitions are properly before us because “the regulations in issue were promulgated not just pursuant to the NLEA but also pursuant to 21 U.S.C. § 371(a), the very statutory section that affords direct review in the United States courts of appeal.” (emphasis in original). Minerals also argue that this court has original jurisdiction over their petitions because the subject regulations affect foods for special dietary uses. Finally, Minerals maintain that public policy considerations justify the assertion by this court of original jurisdiction to review the regulations at issue in this matter.

III.ANALYSIS

Federal courts have limited jurisdiction. Henry v. Office of Thrift Supervision, 43 F.3d 507, 511 (10th Cir.1994). We must dismiss any matter when “it becomes apparent that jurisdiction is lacking.” Penteco Corp. v. Union Gas Sys., Inc., 929 F.2d 1519, 1521 (10th Cir.1991) (citations omitted); Tuck v. United Servs. Auto. Ass’n, 859 F.2d 842, 844 (10th Cir.1988), cert. denied, 489 U.S. 1080, [307]*307109 S.Ct. 1534, 103 L.Ed.2d 839 (1989). “Since federal courts are courts of limited jurisdiction, we presume no jurisdiction exists absent a showing of proof by the party asserting federal jurisdiction.” United States ex rel. Precision Co. v. Koch Indus., Inc., 971 F.2d 548, 551 (10th Cir.1992), cert. denied, — U.S. -, 113 S.Ct. 1364, 122 L.Ed.2d 742 (1993) (citations omitted). Minerals have the burden of demonstrating that their petitions are properly before this court. We address each of Minerals’ arguments under separate headings.

A. Original jurisdiction in this court pursuant to 21 U.S.C. § 371(f)

Minerals assert that we have original jurisdiction over their petitions pursuant to 21 U.S.C. § 371(f)(1). We disagree.

21 U.S.C. § 371(f)(1).1 provides that the United States Court of Appeals for “the circuit wherein any person affected resides or has his principal place of business” has original jurisdiction over challenges to regulations promulgated pursuant to the statutes expressly set forth in section 371(e)(1).2 Section 371(e)(1) does not expressly refer to regulations that are promulgated under sections 343(q) and 343(r). The scope of section 371(e) is explicitly limited to “any regulation under section 343(j), 344(a), 346, 351(b), or 352(a) or (h)....” 21 U.S.C. § 371(e)(1).

The FDA, pursuant to its general rule making authority established in section 371(a),3 promulgated the health claim regulation, the nutrient content regulation, and the nutrition labeling regulation. In 1990, when [308]*308Congress enacted the NLEA and directed the FDA to issue the instant regulations, it did not instruct the FDA to promulgate section 343(q) or 343(r)4 pursuant to 21 U.S.C. § 371(e). We agree with the Second Circuit that when Congress wants regulations to be promulgated pursuant to the procedures set forth in 21 U.S.C. § 371(e), it has demonstrated that it knows how to do so. National Ass’n of Pharmaceutical Mfrs. v.

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53 F.3d 305, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mineral-resources-international-v-united-states-department-of-health-ca10-1995.